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Case 1 :05-cv-01 760-EGS Document 39-5 Filed 02/1 4/2007 Page 1 of 5 



EXHIBIT 3 



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Benz v. ^g^d^t^^^^SoP^ocument 39-5 Filed 02/1 4/2007 Page 2 oP^ l of 4 



Husbands, Amber 

From: Bassel Bakhos [bb@wamcd.com] 

Sent: Thursday, February 01 , 2007 7:03 PM 

To: Husbands, Amber 

Subject: RE: Benz v. Examiner: Meet and confer topics 

Amber: 

Mr. McDaniel and I had a meeting that ran long this evening. You will have our response by 

tomorrow. 



Bassel Bakhos 

Law Offices of William Alden McDaniel, Jr. 

1 18 West Mulberry Street 

Baltimore, MD 21201 

410.685.3810 (phone) 
410.685.0203 (fax) 

443.668.3811 (mobile) 

This message contains information that is privileged, confidential, and exempt from disclosure 
under applicable law. If you have received this communication in error, please notify us 
immediately by collect telephone at 41 0.685.3810; return the original message to us at 118 
West Mulberry Street, Bali, MD 21201 via the U.S. Postal Service; and please do not permit 
any dissemination or distribution of this communication other than to the intended recipient. 
Thank you. 



From: Husbands, Amber [mailto:amberhusbands@dwt.com] 

Sent: Thursday, February 01, 2007 10:02 AM 

To: Bassel Bakhos 

Subject: RE: Benz v. Examiner: Meet and confer topics 

Bassel, 

What is the status of your response to our email? If we don't receive anything from you today, we will have 

to assume that you are not providing any further responses to our discovery. 

Amber 



Amber L, Husbands 

Davis Wright Tremaine LLP 

1 500 K Street N.W. 

Suite 450 

Washington, D.C. 20005 

(202) 508-6619 

(202) 508-6699 (fax) 



2/5/2007 



Benz v. ©greeirteeSV^WiKBCfeS^SopifBocunnent 39-5 Filed 02/1 4/2007 Page 3 oP§ge 2 of 4 



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From: Bassel Bakhos [mailto:bb@wamcd.com] 

Sent: Tuesday, January 30, 2007 4:28 PM 

To: Husbands, Amber 

Subject: RE: Benz v. Examiner: Meet and confer topics 

Amber: 

I am in the process of finalizing our response with Bill. You should have it shortly. 



Bassel Bakhos 

Law Offices of William Alden McDaniel, Jr. 

118 West Mulberry Street 

Baltimore, MD 21201 

410.685.3810 (phone) 
410.685.0203 (fax) 

443.668.3811 (mobile) 

This message contains information that is privileged, confidential, and exempt from disclosure 
under applicable law. If you have received this communication in error, please notify us 
immediately by collect telephone at 410.685.3810; return the original message to us at 118 
West Mulberry Street, Bait., MD 21201 via the U.S. Postal Service; and please do not permit 
any dissemination or distribution of this communication other than to the intended recipient. 
Thank you. 



From: Husbands, Amber [mailto:amberhusbands@dwt.com] 

Sent: Tuesday, January 30, 2007 3:56 PM 

To: Bassel Bakhos 

Subject: RE: Benz v. Examiner: Meet and confer topics 

Bassel, 

Just following up on this email - when do you expect to send us a response? 

thanks, 

Amber 



Amber L. Husbands 

Davis Wright Tremaine LLP 

1500 K Street KW. 

Suite 450 

Washington, D.C. 20005 

(202) 508-6619 

(202) 508-6699 (fax) 



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From: Bassel Bakhos [mailto:bb@wamcd.com] 
Sent: Monday, January 29, 2007 1:15 PM 



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To: Husbands, Amber; William McDaniel 
Cc: Handman, Laura; Gondelman, Larry 
Subject: RE: Benz v. Examiner: Meet and confer topics 

Amber: 

We will respond to the points you raised below in writing by the end of the day. As such, we 
do not see the need for a meet and confer telephone conference this afternoon. Let us know if 
you would like to schedule a call for tomorrow afternoon after reviewing our response. 



Bassel Bakhos 

Law Offices of William Alden McDaniel, Jr. 

1 18 West Mulberry Street 

Baltimore, MD 21201 

410.685.3810 (phone) 
410.685.0203 (fax) 

443.668.3811 (mobile) 

This message contains information that is privileged, confidential, and exempt from disclosure 
under applicable law. If you have received this communication in error, please notify us 
immediately by collect telephone at 410.685.3810; return the original message to us at 118 
West Mulberry Street, Bait., MD 21201 via the U.S. Postal Service; and please do not permit 
any dissemination or distribution of this communication other than to the intended recipient 
Thank you. 



From: Husbands, Amber [mailto:amberhusbands@dwt.com] 
Sent: Monday, January 29, 2007 12:45 PM 
To: William McDaniel; Bassel Bakhos 
Cc: Handman, Laura; Gondelman, Larry 
Subject: Benz v. Examiner: Meet and confer topics 

Bill and Bassel: 

In preparation for our meet and confer this afternoon, here is a list of items we would like to discuss: 

First , there are a number of requests that you objected to as irrelevant. Please explain why these requests 
are irrelevant, as we believe they are directly relevant to Plaintiffs damage claims: 

- Medical and psychological records (document requests 32 through 35, and interrogatories 2 and 3): 
Plaintiff claims damages for mental anguish in her Amended Complaint and in her interrogatory responses 
(nos. 9 and 10). She identifies physical symptoms of her mental anguish and exacerbation of past illness. 
Medical and psychological records - both before and after the Column - are relevant to her damage claims. 

- Income tax records (document requests 5 through 7): Plaintiff claims damages for financial loss, injury to 
reputation, as well as loss of current and future business opportunities. Is Plaintiff conceding that she will 
not seek damages for these claimed losses? 

- Disability benefits (document request 8): this is relevant to Plaintiffs claims that she has suffered physical 



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symptoms of mental anguish and exacerbation of past illness. 

Second , there are discovery requests to which you did not fully respond: 

- Interrogatories relating to damage claim (9 through 12): there is no itemized list of damages claimed by 
Plaintiff, or calculation of how Plaintiff arrived at her claimed damage amount. 

- Documents related to Ms. Benz's subscription to JDate (document request no. 20): these documents are in 
Ms. Benz's possession, as no one else can access her profile. Please provide us with a copy of her JDate 
profile. 

- Documents related to Plaintiffs calendar, phone records, and credit card receipts (doc requests 19, 22, 24): 
please confirm that Ms. Benz has no documents related to these requests. 

- Emails with Mr. Bisney (document request no. 18): Plaintiff did not produce emails she sent to Mr. Bisney, 
only those received from him. Does she possess the emails sent by her to Mr. Bisney? 

- Pictures (document request no. 10): We are aware of other pictures of Ms. Benz with Mr. Bisney or taken 
by Mr. Bisney that have not been produced. Is Ms. Benz in possession of any other pictures that are 
responsive to this request? 



Third , you do not provide a privilege log for those documents for which you claim attorney-client or work- 
product privilege. Please produce this privilege log. Alternatively, we may agree that requests on both sides 
be deemed to exclude all attorney client privilege or work product post-complaint. 

We look forward to speaking with you at 3:30 today. 

Amber L. Husbands 

Davis Wright Tremaine LLP 

1500 K Street N.W., Suite 450 

Washington, D.C. 20005 

(202)508-6619 

(202) 508-6699 (fax) 



2/5/2007